Justia Oklahoma Supreme Court Opinion Summaries

A group of medical providers sued a former employee for breach of an employment agreement. The employee counterclaimed, alleging he was owed unpaid wages and bonuses. The providers initially raised "failure to state a claim" as their sole affirmative defense. However, after nearly four years of litigation, they attempted to argue for the first time that the contract was illegal and therefore void. The lower court found that the providers had waived this affirmative defense and issued a judgment in favor of the employee. The providers appealed, and the Court of Civil Appeals reversed, concluding that the lower court had abused its discretion by refusing to consider the providers' claim of illegality.The Supreme Court of the State of Oklahoma disagreed with the Court of Civil Appeals. It held that the trial judge did not abuse her discretion in striking the providers' last-minute effort to raise a new affirmative defense. The court noted that the providers had failed to raise the illegality defense in their initial responsive pleading and did not seek to amend their answer in a timely manner. Furthermore, the providers did not raise the illegality defense until after the trial court had already awarded summary judgment to the employee on the issue of breach of contract, more than ten months after the close of discovery, more than nine months after the lower court's deadline for filing dispositive motions, and almost four years after the original lawsuit was filed. The court concluded that the record was sufficient to support a finding that the providers' delay was unjustified and prejudicial. The court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's order striking the illegality affirmative defense, and remanded the case to the Court of Civil Appeals to resolve any remaining undecided issues raised in the appeal. View "Tulsa Ambulatory Procedure Center v. Olmstead" on Justia Law

Spencer Mathis and Jaden Fenstermaker, who worked as delivery drivers for Amazon in Tulsa, Oklahoma, were fired by their employer, James Kerr, after Mathis filed a workers' compensation claim. The plaintiffs alleged that Kerr had retaliated against them for pursuing the claim and filed a lawsuit against him. Kerr moved to compel arbitration based on the arbitration provisions in the plaintiffs' employment contracts. The plaintiffs objected, arguing that federal and state law exempted them from arbitration.The trial court granted Kerr's motion to compel arbitration and stayed the lawsuit until the completion of arbitration. The plaintiffs appealed this decision, but the Court of Civil Appeals affirmed the trial court's ruling.The Supreme Court of the State of Oklahoma granted certiorari to review the case. The court held that employees who deliver Amazon packages are exempt from arbitration under federal law. The court also found that the district court's exclusive jurisdiction over retaliatory discharge claims precluded arbitration of those claims under Oklahoma law. The court reversed the trial court's decision, vacated the Court of Civil Appeals' opinion, and remanded the case for further proceedings. View "MATHIS v. KERR" on Justia Law

The case revolves around an incident where an employee, Leonard Bernstein, shot his co-worker, Christopher Bayouth, at their workplace, Morgan Stanley's Oklahoma City branch. Bernstein, who was suffering from mental deficiencies, believed he was acting in self-defense due to his delusional state. After the shooting, Bayouth filed a lawsuit against Bernstein for willful and intentional acts, assault, battery, and intentional infliction of emotional distress. Bernstein passed away, and his estate was substituted as the defendant. The estate argued that Bayouth's exclusive remedy was through the Administrative Workers' Compensation Act (AWCA), as he had received workers' compensation benefits.The District Court of Oklahoma County granted summary judgment in favor of Bernstein's estate, ruling that the exclusive remedy provision of the AWCA protected Bernstein regardless of whether he was acting within his course and scope of employment when the shooting occurred. The court reasoned that the focus was on whether the injured employee was acting within the course and scope of his employment at the time of the incident, not the employee who caused the injury.The Supreme Court of the State of Oklahoma disagreed with the lower court's interpretation. The court held that for the exclusive remedy provision under the AWCA to apply, the employee who injures another employee must be acting within the course and scope of their employment when the incident occurs. The court found that the parties disputed whether Bernstein was acting within the course and scope of his employment when he shot Bayouth. Therefore, the court reversed the lower court's decision and remanded the case for further proceedings. View "Bayouth v. Dewberry" on Justia Law

The case involves Nancy Anaya-Smith, the next of kin of Michael Brian Smith, who was killed in a single-car accident while he was a passenger in a company vehicle owned by Fixtures & Drywall Company of Oklahoma (FADCO). The vehicle was being driven by Smith's coworker, Duane Clark. Anaya-Smith alleges that Clark's negligence caused the fatal accident. At the time of the accident, FADCO maintained an insurance policy with Federated Mutual Insurance Company (Federated). The policy provided up to $1,000,000 of liability coverage per accident and an additional $6,000,000 of liability coverage per accident under an umbrella policy. However, FADCO had rejected uninsured motorist (UM) coverage for all employees, except for its directors, officers, partners, owners, and their family members.The United States District Court for the Western District of Oklahoma granted summary judgment in favor of Federated, concluding that the vehicle was an uninsured vehicle at the time of the accident because Clark is immune from tort liability under the workers' compensation exclusive remedy provision, and that FADCO's policy providing UM coverage for some individuals who qualify as insureds but rejecting UM coverage for other insureds does not violate Oklahoma law. Anaya-Smith appealed from the summary judgment order.The Supreme Court of the State of Oklahoma answered the first certified question in the affirmative, holding that the vehicle qualifies as an uninsured motor vehicle within the meaning of Oklahoma law. The court answered the second certified question in the negative, concluding that the plain language of Oklahoma law requires a named insured to either elect or reject uninsured/underinsured motorist coverage for all insureds under the policy, treating every insured in the same manner. The court declined to answer the third certified question as the record was undeveloped and the parties did not submit legal arguments pertaining to it. View "Anaya-Smith v. Federated Mutual Insurance Co." on Justia Law

In this case, the petitioner, Gary Stricklen, filed a claim for permanent total disability with the Workers' Compensation Commission, which was dismissed by an administrative law judge. The Multiple Injury Trust Fund (MITF) argued it was not liable because all of Stricklen's injuries occurred while he was employed by the same employer. The Supreme Court of the State of Oklahoma held that the phrase "subsequent employer" in 85A O.S.Supp.2019 § 32 refers to the employer at the time of the employee's "subsequent injury" referenced in the same statute, which is used for the purpose of that statute for a claim against the MITF. The court reversed the Commission's order that was based on the erroneous view of the statutory language and remanded the case for further proceedings. The petitioner's constitutional issue was not addressed because the court's interpretation of the statutory language did not require it. View "STRICKLEN v. MULTIPLE INJURY TRUST FUND" on Justia Law

Kevin Cantwell worked for Flex-N-Gate for 28 years during which he sustained numerous work-related injuries. He was awarded permanent partial disability (PPD) benefits for these injuries under the law as it existed before February 1, 2014, referred to as Title 85. After this date, workers' compensation claims were governed by a new law, Title 85A, under the Administrative Workers' Compensation Act (AWCA). Cantwell sustained three more injuries after the enactment of AWCA and was again awarded PPD benefits. However, the Workers' Compensation Commission denied payment of these benefits based on their interpretation of Section 46(H) of the AWCA, which limited the total weeks of PPD benefits to 350.The Supreme Court of the State of Oklahoma, in this case, disagreed with the Commission's interpretation. The court determined that the 100% limitation on PPD benefits under Section 45(C)(1) of the AWCA controls over the number of weeks when awarding compensation for PPD. This is particularly applicable where a claimant has compensable awards for job-related injuries that occurred both before and after February 1, 2014. The court vacated the Commission's order in each case and remanded the cases for further proceedings consistent with this opinion. View "CANTWELL v. FLEX-N-GATE" on Justia Law

Plaintiff Steven Bird, an independent contractor hired to install a new checkout lane at Defendant Pruett's Food store, was injured after falling off a ladder Defendant had supplied to aid Plaintiff in completing the work. Plaintiff initiated a negligence action, seeking damages from his injuries and lost wages. Plaintiff presented his case at trial, after which Defendant demurred to Plaintiff's evidence. The trial court sustained the demurrer. Plaintiff appealed. The Oklahoma Supreme Court held that Plaintiff failed to establish that Defendant owed him a duty of care. View "Bird v. Pruett's Food, Inc." on Justia Law

Erasmo Paredes sustained an on-the-job injury in late 2019. He continued working for his employer, Schlumberger Technology Corp., until January 30, 2020. His employer's insurance carrier, Travelers Indemnity Company of America, provided voluntary medical treatment to Paredes from January 3, 2020, through February 14, 2020. Paredes's CC-Form 3 Claim for Compensation was filed on December 3, 2020, alleging an injury date of December 29, 2019. This claim was filed ten months after Paredes's last medical treatment, but within one year from the date of his injury. Travelers's counsel entered an appearance in the Workers' Compensation case on December 22, 2020. On February 18, 2021, the affidavit of Travelers's claims handler was filed with attachments indicating Travelers provided medical treatment to Paredes in the total amount of $1,371.47. No disability benefits were paid. On the same date, counsel for Travelers filed the CC-Form 10 Answer and Notice of Contested Issues on behalf of Schlumberger raising the defense of statute of limitations pursuant to Section 69(A)(1) of Title 85 A. 1 Schlumberger also denied compensable injuries, alleged pre-existing conditions pursuant to 85A O.S. Supp. 2019, § 2(9)(b)(6), and denied benefits. An ALJ issued an order that was filed on May 13, 2021, concluding that Paredes's claim was not barred by Section 69(A)(1). Schlumberger appealed to the Workers' Compensation Commission ("Commission"), and the parties filed written arguments. Oral argument before the Commission was held on January 14, 2022. The Commission, sitting en banc, affirmed the Decision of the ALJ by order filed January 18, 2022. Schlumberger appealed to the Oklahoma Supreme Court seeking review of the Commission's interpretation of 85A O.S. Supp. 2019, § 69(A)(1). Finding no error in the Commission's interpretation, the Supreme Court affirmed. View "Schlumberger Technology Corp. v. Travelers Indemnity Co. of America" on Justia Law

In 2018, Mwande Serge Kpiele-Poda ("Employee") was injured at a wellsite while repairing a conveyor that activated and crushed his legs. While Employee's Workers' Compensation claim was still pending, he filed a petition asserting negligence and products liability against his employers, two wellsite operators, and the manufacturers and distributors of the conveyor. Ovintiv Mid-Continent, Inc. was named in the body of the petition but omitted from the caption. After the statute of limitations period expired, Employee amended his petition to add Ovintiv Mid-Continent, Inc. as a defendant in the petition's caption. A second amended petition added other parties. Ovintiv Mid-Continent, Inc. moved to dismiss arguing the claim was time-barred because the amended petition did not relate back to the first petition. Employee's employers also moved to dismiss arguing the Administrative Workers' Compensation Act and Oklahoma precedent precluded employees from simultaneously maintaining an action before the Workers' Compensation Commission and in the district court. The district court granted each dismissal motion and certified each order as appealable. The Oklahoma Supreme Court retained and consolidated Employee's separate appeals, holding: (1) the district court erred when it dismissed Employee's action against Ovintiv Mid-Continent, Inc. as time-barred; and (2) the district court properly dismissed Employee's intentional tort action for lack of subject matter jurisdiction. View "Kpiele-Poda v. Patterson-UTI Energy, et al." on Justia Law

Plaintiff-appellant Jayen Patel, M.D. brought a tort claim for wrongful termination against defendant-appellee Tulsa Pain Consultants, Inc. (TPC). The trial court found Patel was not an at-will employee and entered a directed verdict in favor of TPC. Patel appealed, and the Court of Civil Appeals affirmed. TPC moved for appeal-related attorney fees, which the Court of Civil Appeals denied. The Oklahoma Supreme Court granted certiorari to determine whether TPC had a contractual right to recover attorney fees as the prevailing party in Patel's wrongful termination claim. After review, the Supreme Court found that the specific language in the parties' employment agreement authorized attorney fees in this case. View "Patel v. Tulsa Pain Consultants" on Justia Law